Justia Criminal Law Opinion Summaries

The case involved a defendant who, while driving a sport utility vehicle (SUV) without a license, struck and fatally injured a pedestrian at an intersection in Waterbury, Connecticut. The defendant fled the scene without stopping. Several miles away, after the SUV broke down and partially blocked a residential driveway, the defendant, with the help of the homeowner and a taxi driver, pushed the damaged SUV into the driveway, leaving it at the front of other vehicles with its damaged front end fully visible from the street. The defendant did not attempt to hide the SUV further, nor did he inform the homeowner of the accident.A jury in the Superior Court for the judicial district of Waterbury found the defendant guilty of evasion of responsibility in the operation of a motor vehicle and tampering with physical evidence, based on the state’s theory that the defendant concealed the SUV to impair its availability in a criminal investigation. The Appellate Court affirmed the convictions, holding that a rational juror could find the act of concealment based on the context and circumstances, including the defendant’s flight from the scene and the temporary abandonment of the SUV in a private driveway.On further review, the Supreme Court of Connecticut concluded that the evidence was insufficient to establish concealment under General Statutes § 53a-155 (a). The court held that simply leaving the SUV in a visible spot at the front of a driveway, where its damage was apparent from the street, did not constitute concealment as required by the statute. The Supreme Court reversed the tampering conviction, directing the trial court to enter a judgment of acquittal on that charge and leaving resentencing, if any, to the trial court’s discretion. The remaining conviction was affirmed. View "State v. Bolden" on Justia Law

The case involved a fatal shooting that followed a car accident in Hartford, Connecticut. The defendant, after colliding with the victim’s vehicle, agreed to pay for the damages and arranged to meet the victim later that day. Surveillance footage and eyewitness accounts linked the defendant to the scene, describing his distinctive clothing and actions. Evidence showed the defendant met with the victim, shot him multiple times, and fled the scene. Forensic analysis detected gunshot residue on the defendant’s clothing, and cellphone data further corroborated his involvement. The defendant was subsequently arrested and charged with murder and criminal possession of a firearm.At trial in the Superior Court for the judicial district of Hartford, the jury found the defendant guilty of murder, and the court found him guilty of criminal possession of a firearm. The defendant appealed directly to the Connecticut Supreme Court, raising several unpreserved constitutional claims. He argued that his right to confrontation was violated when the State’s gunshot residue expert testified based on data and notes from a nontestifying analyst, and when the prosecutor elicited testimonial hearsay on cross-examination. He also alleged prosecutorial impropriety for introducing facts not in evidence during cross-examination.The Connecticut Supreme Court held that the claim regarding the expert’s reliance on the nontestifying analyst’s materials failed because the record was inadequate to determine whether those materials were testimonial. The court declined to adopt the State’s proposed rule barring all unpreserved confrontation claims and reaffirmed that such claims may still be reviewed if the record is sufficient. The court further held there was no confrontation clause violation or prosecutorial impropriety regarding the cross-examination, as the questions did not introduce hearsay or inadmissible evidence. The judgment of conviction was affirmed. View "State of Connecticut v. Bester" on Justia Law

A defendant was convicted of multiple sexual offenses arising from the abuse of a minor, J, who lived with him and her mother over several years. The victim alleged that the defendant, who acted as a father figure, committed various acts of sexual, physical, and emotional abuse while the mother was at work. After the defendant was incarcerated for a separate domestic dispute, J disclosed the abuse to her mother, which eventually led to a police report and a forensic interview at a child advocacy center. Subsequently, a pediatrician conducted a medical examination and relied on the forensic interview report to obtain a history of the alleged abuse. The physical exam results were normal and did not confirm or refute the allegations.The case was tried in the Superior Court in the judicial district of New Britain. During trial, the state sought to admit statements J made during her forensic interview through the testimony of the interviewer, arguing these were admissible under the medical diagnosis and treatment exception to the hearsay rule. The defense objected, contending the interview lacked a medical purpose. The trial court overruled the objection and admitted the statements. The jury found the defendant guilty on all counts, and the court imposed a substantial prison sentence. The defendant appealed, raising two main issues: the admission of the forensic interview statements as hearsay, and the denial of a special jury instruction on child witness credibility.The Connecticut Supreme Court reviewed the appeal. It clarified that, for statements to be admissible under the medical treatment exception, the declarant must be motivated, at least in part, by a desire to obtain medical diagnosis or treatment, and the statements must be reasonably pertinent to that end. The Court found the trial court abused its discretion in admitting the forensic interview statements because there was insufficient evidence that J understood the interview had a medical purpose. However, the Court concluded this error was harmless since the evidence was cumulative of J’s testimony and not emphasized by the prosecution. The Court further held the trial court did not abuse its discretion in denying a special child credibility instruction, and it declined to modify its approach to such instructions. The judgment of conviction was affirmed. View "State of Connecticut v. Giovanni D." on Justia Law

A five-year-old child and her mother, recently arrived from the Dominican Republic, were staying with family in New Britain, Connecticut. The defendant, who was married to the mother's niece, lived in the same apartment. On New Year's Eve, the defendant sexually assaulted the child. Later that evening at a family party, the child told her mother that the defendant had kissed her, and after further questioning, disclosed more details of the assault. The next day, the mother confronted the defendant, who made incriminating admissions both in person and via text. Police interviewed the defendant at the station after he voluntarily agreed to meet and requested a Spanish-speaking detective. During the interview, which was conversational and not confrontational, the defendant confessed to inappropriate sexual conduct.The Superior Court, Judicial District of New Britain, denied the defendant’s pretrial motion to suppress his statements to police, finding he was not in custody for Miranda purposes. At trial, the court admitted the child’s statements to her mother under the spontaneous utterance exception to hearsay, and limited the testimony of the defense expert regarding the U visa program, which provides immigration benefits to victims of certain crimes who cooperate with law enforcement. The jury convicted the defendant of sexual assault in the first degree and risk of injury to a child.On direct appeal to the Connecticut Supreme Court, the defendant argued the trial court erred in denying his suppression motion, admitting the victim’s hearsay statements, and restricting expert testimony, and further sought review of confidential personnel records of one detective. The Connecticut Supreme Court held that the trial court properly denied the suppression motion, as the defendant was not in custody. The admission of the child’s statements was error but harmless, given other strong evidence. The limitations on the expert’s testimony did not deny due process or affect the verdict. Review of the confidential records revealed no material requiring disclosure. The conviction was affirmed. View "State of Connecticut v. Lazaro D." on Justia Law

A seventeen-year-old defendant was charged with murder after the shooting death of a victim in a Bridgeport housing complex stairwell. Surveillance footage showed the defendant leading the victim into the building and exiting alone minutes later, covering his face with a mask. The victim was later found naked and bleeding outside the basement door, having been shot six times. Police investigation led to a search of the defendant’s home, where a .45 caliber pistol and matching ammunition were found in his bedroom. The defendant, interviewed at home in the presence of his legal guardian, admitted to owning the gun and being with the victim but denied involvement in the shooting. Nineteen minutes into the interview, he invoked his right to remain silent, but questioning continued. The defendant was later located in Florida and returned to Connecticut for trial.In the Superior Court for the judicial district of Fairfield, the defendant moved to suppress statements made during the police interview, arguing he had not knowingly and voluntarily waived his Miranda rights. The court found, under the totality of the circumstances, that the waiver was valid, considering the defendant’s age, education, prior experience with law enforcement, and the presence of his guardian. The court suppressed only statements made after the defendant invoked his right to remain silent. The jury convicted the defendant of murder, and he was sentenced to forty-five years’ incarceration.On appeal to the Connecticut Supreme Court, the defendant challenged the validity of his Miranda waiver, sought greater protection under the state constitution, alleged prosecutorial impropriety, and objected to a consciousness of guilt jury instruction. The Supreme Court held that the waiver was knowing, intelligent, and voluntary, declined to adopt a rule requiring consultation with an interested adult before a juvenile’s waiver, found no prosecutorial impropriety, and determined any error in the consciousness of guilt instruction was harmless. The judgment was affirmed. View "State v. Cooper" on Justia Law

In 1984, four women in Connecticut were robbed and sexually assaulted in their homes by an unknown assailant. The perpetrator blindfolded, restrained, and threatened each victim, then stole items before leaving. Police collected physical evidence from the crime scenes, but DNA testing was not available at the time. Years later, advances in forensic science allowed the state laboratory to develop DNA profiles from the evidence, which were uploaded to the Combined DNA Index System (CODIS). In 2020, a private forensic company provided investigative leads, ultimately implicating the defendant. Police lawfully collected trash from the defendant’s residence, including a belt, and submitted it for DNA analysis without a warrant. The DNA extracted from the belt matched the crime scene profiles. Police then obtained a warrant for a confirmatory DNA sample, which further implicated the defendant.The defendant was charged in the Superior Court for the judicial district of Hartford with eight counts of kidnapping in the first degree. At trial, the court instructed the jury on the elements of kidnapping, including the factors from State v. Salamon, which help determine whether restraint exceeded what was necessary for the underlying crimes. The next day, the court provided the jury with a flowchart outlining the kidnapping elements, but the chart omitted reference to the Salamon factors. The jury found the defendant guilty on all counts, and he was sentenced to seventy-two years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that the warrantless collection and analysis of his DNA from the discarded belt violated his rights under the Fourth Amendment and the Connecticut Constitution, and that the omission of the Salamon factors from the flowchart misled the jury. The Connecticut Supreme Court held that neither the collection nor the analysis of DNA from the discarded belt constituted a search under the Fourth Amendment or the state constitution when performed for identification purposes only. The court also found that the jury was not misled by the flowchart, as the full instructions included the Salamon factors and the jury was properly directed to rely on those instructions. The judgment of conviction was affirmed. View "State v. Sharpe" on Justia Law

The defendant was convicted of murder and risk of injury to a child after fatally stabbing his long-term girlfriend in the presence of her twelve-year-old son. The relationship had deteriorated due to the defendant’s substance abuse and lack of financial contribution, leading the victim to attempt to end the relationship and remove the defendant from their shared home. On the morning of the incident, after a series of escalating arguments and failed attempts to have the defendant leave, the victim was attacked and killed. The defendant fled the scene, evaded police, and was eventually apprehended several days later.The case was tried before the Superior Court in the judicial district of New London. At trial, the defendant requested a jury instruction on the affirmative defense of extreme emotional disturbance, arguing that his mental state at the time of the killing warranted consideration of a lesser offense. The trial court denied this request, finding insufficient evidence that the defendant was under the influence of an extreme emotional disturbance, and the jury convicted him of both charges. The defendant appealed his conviction directly to the Connecticut Supreme Court, challenging the denial of the requested jury instruction.The Connecticut Supreme Court reviewed whether the trial court erred in refusing to instruct the jury on the affirmative defense of extreme emotional disturbance. The Court held that the trial court acted properly, concluding that no rational juror could find by a preponderance of the evidence that the defendant experienced an extreme emotional disturbance at the time of the murder. The Court emphasized the defendant’s actions before and after the crime, which demonstrated self-control and consciousness of guilt, and found that the evidence did not support the required loss of self-control. The judgment of conviction was affirmed. View "State v. Henderson" on Justia Law

The defendant was convicted of murder with special circumstances, home invasion, arson in the second degree, and robbery in the first degree, following a violent home invasion in Griswold, Connecticut. The crimes involved the planned theft of a gun safe and guns from the Lindquist family home, orchestrated with the help of the victims’ son, Matthew, who was later killed by the defendant and his sister, Ruth. After killing Matthew in a nearby wooded area, the defendant and Ruth entered the Lindquist home, killed Kenneth and Janet Lindquist, stole various items, and set the house on fire. The defendant’s cell phone was seized by police without a warrant after an interview, and a subsequent warrant authorized the search and seizure of “all data” from the phone, without any temporal limitations.In the Superior Court for the judicial district of New London, the defendant moved to suppress evidence obtained from his cell phone, arguing the seizure was illegal and the warrant was unconstitutional due to its broad scope. The trial court found the seizure proper and, applying the severance doctrine, limited admissible evidence to data created or received within a two-week period surrounding the crimes, suppressing data outside that window. The jury convicted the defendant on most counts, and the court vacated certain convictions before sentencing him to life imprisonment without parole.On appeal to the Connecticut Supreme Court, the defendant challenged the constitutionality of the cell phone search warrant. The Supreme Court assumed, without deciding, that the warrantless seizure was constitutional, but held that the warrant violated the Fourth Amendment’s particularity requirement because it authorized a search of all data without content or time limits. The Court further found the trial court erred in applying the severance doctrine to cure the warrant’s deficiencies. Nevertheless, the Supreme Court concluded that the error was harmless beyond a reasonable doubt, as the cell phone evidence was cumulative and the state’s case was strong without it. The judgment of conviction was affirmed. View "State v. Correa" on Justia Law

A woman was found dead in her apartment after her boyfriend, who had spent the night elsewhere, returned and discovered her body hidden in a closet. The apartment was in disarray, and drugs and a cell phone were missing. The defendant, who knew the victim and her boyfriend through drug transactions, was identified as having been at the apartment the night of the murder. Forensic evidence linked the defendant to the crime scene, including blood matching the victim on his clothing and blood matching the defendant at the scene. The defendant was arrested shortly after the murder, and additional evidence was gathered, including statements from jailhouse informants.The defendant was first convicted of murder in the Superior Court for the judicial district of New London, but the Connecticut Supreme Court reversed that conviction and ordered a new trial due to the improper admission of evidence obtained in a warrantless search. Before the second trial, the defendant requested a new probable cause hearing, which the trial court denied, reasoning that the reversal did not invalidate the original probable cause finding. The trial court also denied motions to exclude testimony from two jailhouse informants: one, who had suffered a stroke and claimed memory loss, and another whose reliability was challenged.On appeal, the Connecticut Supreme Court held that the defendant was not entitled to a second probable cause hearing after reversal and remand for a new trial, as neither the state constitution nor the relevant statute required it absent a jurisdictional defect. The court also held that admitting the prior written statement of the former cellmate did not violate the defendant’s confrontation rights, as the witness was present, took an oath, and answered questions, even if he claimed memory loss. The court further found no abuse of discretion in admitting the statement as a prior inconsistent statement or in finding the jailhouse informant’s testimony reliable. The judgment of conviction was affirmed. View "State v. Jacques" on Justia Law

The petitioner, who had previously been convicted of robbery in the first degree following a guilty plea, filed a habeas petition in 2018 challenging that conviction on the grounds of ineffective assistance of trial counsel. In 2020, the petitioner was deported to Jamaica. After deportation, his habeas counsel was unable to contact him or his family members. In early 2021, the habeas court scheduled a hearing to consider dismissing the petition due to the petitioner’s failure to appear and prosecute the case with due diligence. Following the hearing, the court dismissed the habeas petition for lack of prosecution.Approximately fifteen months after the dismissal, the petitioner filed a motion to open the judgment, arguing that he had not received notice of the hearing and that his counsel had failed to make reasonable efforts to notify him or communicate effectively. The Superior Court denied the motion, finding that the petitioner had not established a recognized basis for opening the judgment beyond the four-month period prescribed by Connecticut General Statutes § 52-212a. The petitioner appealed, and the Connecticut Appellate Court reversed, holding that a claim of ineffective assistance of habeas counsel was sufficient to invoke the habeas court’s common-law authority to grant a late motion to open a judgment.On further appeal, the Supreme Court of Connecticut reviewed whether ineffective assistance of habeas counsel could serve as a common-law exception to the four-month deadline in § 52-212a. The Supreme Court held that the phrase “unless otherwise provided by law” in § 52-212a does not include a new judicially created common-law exception for ineffective assistance of habeas counsel. The Court reasoned that such an exception would conflict with the statutory scheme governing habeas corpus, including requirements for expedient resolution and custody status. The Supreme Court reversed the Appellate Court’s judgment and directed affirmation of the habeas court’s denial of the motion to open. View "Clue v. Commissioner of Correction" on Justia Law